Stemler v. Florence
United States Court of Appeals for the Sixth Circuit
350 F.3d 578 (6th Cir. 2003)
After a drunken altercation involving Susan Stemler, Conni Black, and Steve Kritis, police officers (officers) (defendants) arrested Stemler. The officers allegedly put Black into Kritis’s truck. Kritis drove away, and Black was killed in a crash. Black’s estate administrator (administrator) (plaintiff) sued the officers, the city, and the county sheriff (defendants) for wrongful death in state court. The circuit court granted summary judgment to the defendants, but the appellate court reversed. The Kentucky Supreme Court reversed, holding that Black had not been restrained or in police custody at the time of her death and, in dicta, that she had never been in custody. Thus, the supreme court concluded that there was no special relationship creating a duty to Black. The administrator also sued in federal court under 42 U.S.C. § 1983. The officers moved to dismiss for failure to state a claim, which was granted. The city and county moved for summary judgment, which was also granted. The administrator appealed. The United States Court of Appeals for the Sixth Circuit affirmed as to the city and county, but reversed the dismissal of the claims against the officers. At the time, the state court had ruled that Black was not in custody at the time of her death, and this court concluded that those holdings had preclusive effect. The case was remanded, and the district court held that the administrator was precluded from relitigating the issue of whether Black was in custody. The administrator appealed.
Rule of Law
Holding and Reasoning (Boggs, J.)
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